Saturday, September 13, 2008

Hawkins v. McGee (a.k.a. hairy hand)

Hawkins v. McGee
Supreme Court of New Hampshire
84 N.H. 114, 146 A. 641 (1929)

Justice Branch delivered opinion

Facts:
  • Operation consisted of removal of scar tissue from palm of plain.'s right hand and grafting of skin taken from plain's chest
  • scar tissue was result of severe burn caused by contact w/ electric wire (boy was approx. 9 yrs old at time of injury)
  • Father and son went to office and doc mentioned 3-4 day hospital stay and returning to work with a "perfect hand"
  • Def's statement "I will guarantee to make the hand a 100% perfect hand" before operation was consented to
  • def repeatedly solicited family to allow him to complete surgery on boy's hand
  • doc wanted to experiment on skin grafting
  • Trial by jury and verdict for plaintiff
  • Def. moved to set aside verdict because damages awarded were excessive
  • Judge agreed and made conditioned ruling advising verdict would be set aside unless plain. agreed to accept $500
  • Plain. refused and verdict set aside and plain. went home w/o $500 (excepted)
Issue:
What damages should the plain. receive, if any?

Holding: Measure of plain.'s damage is the difference between the value to him of a perfect hand or a good hand and the value of his hand in its present condition, including any incidental consequences fairly within the contemplation of the parties when they made their contract.

Reasoning:
  • Pain was part of contribution plain. was willing to make for def. to produce a good hand
  • Def.'s rqsts for instruct. were loosely drawn and properly denied
  • would have been misleading to instruct jury as def. rqstd
  • Doc and plain. both understood doc was guaranteeing a perfect result from the operation
Judgment: New trial

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